Darrell D. and Jane E. Moran - Page 1

                                 T.C. Memo. 1997-412                                  

                               UNITED STATES TAX COURT                                

                    DARRELL D. AND JANE E. MORAN, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5374-96.                Filed September 17, 1997.           

               Darrell D. and Jane E. Moran,  pro sese.                               
               James Gehres, for respondent.                                          

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               GERBER, Judge:  Respondent, by means of a notice mailed                
          February 16, 1996, determined an $11,701 income tax deficiency              
          for petitioners’ 1994 taxable year.  The sole issue for our                 
          consideration is whether the amount of $37,840 received by                  
          Darrell D. Moran1 (petitioner) as the result of the termination             

               1 Jane E. Moran is a petitioner solely because she filed a             

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